HILLARY RODHAM CLINTON NEW YORK
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WASHINGTON, ED5O3204
January 2009
VIA HAND DELIVE
Mr. James Theesin
Deputy Legal Adviser and
Designated Agency Ethics Official
US. Department State
Washington, DACD 20520-6310
Subject: Ethics Undertakings
Dear Mr. Thessin; committed the highest standards ethical conduct for govemment officials.
con rmed Secretary State, asrequired U.S.C. Z08(a), will not participate
personally and substantially any particular matter that has direct and predictable effect nancial interests those any person whose interests are imputed me, unless rst
obtain written waiver, pursuant section 208(b)(l), qualify for regulatory exemption,
pursuant section 208(b)(2). understand that the interests the following persons are
imputed me: spouse; any general partner aparttrership whichl limited
general partner; any organization which serve officer, director, trustee, general partner
employee; and any person organization with which negotiating have arrangement
concerning prospective einployment. currently hold and will continue hold position with The Clinton Family Foundation,
which maintains all its assets cash. con rmed Secretary State, will not participate
personally and substantially any,pa.rticular matter that has direct and predictable effect upon
this foundation, unless first obtain Written waiver qualify for regulatory exemption. husband founded The William Clinton Foundation, Althcugi neither husband nor
has any financial interest duciary role with The William Clinton Foundation (or The
Clinton Global Initiative), husband has been active with this not-forvprofit organization since
its inception. For the duration appointment Secretary con rmed, will not
participate personally and substantially any particular matter involving speci parties
which The William Clinton Foundation (or The Clinton Global Initiative) party
represents party, unless first authorized participate, pursuant C.F.R. 2635,502(d). spouse speaks, writes and consults for compensation. con rmed, required USC.
208(a), will not participate personally and substantially any particular matter that has
direct and predictable effect upon his compensation from persons entities that pay him, unless first obtain written waiver pursuant U.S.C. 208(b)(l) qualify for regulatory
exemption pursuant USC. 208(b)(2). addition, will not participate personally and
substantially any particular matter involving speci parties which aclient spouse party represents party, unlessl first authorized participate, pursuant C.F.R.
2635.502(d). Iunderstand that, for purposes this wmmitrnent, client spouse
anyone with whom has contract for his consulting services and anyone with whom
negotiating for such contract. avoid even the appearance conflict, husband and are also Voluntarily taking steps
that above and beyond the requirements the law and ethics regulations with respect his
personal income earned from speeches and consulting well with respect the William
Clinton Foundation and its initiatives. these steps beyond the requirements the law and
the ethics regulations, these additional steps are outlined separately the attached MOU
between the Clinton Foundation and the Office the President Elect and the attached letter from husband counsel, David Kendall. understand that you intend assess the facts and
circumstances the additional voluntary measures outlined the MOU and attached letter
specificallyvreviewing potential speech hosts, business entities, and certain country Contributions the Foundation the context the standards and the procedures C.F.R. 2635502
determine whether appearance con iet may exist, consultation with the White House appropriate. ask that you advise applicable steps that may avoid any actual
apparent con. .ict.s interest. currently associated with three federal political organizations, HillPAC, amulticandidate
political committee which Honorary Chair, and two principal campaign committees,
Friends Hillary, which was formed support Senate elections, and Hillary Clinton for
President, which was formed support presidential campaign. All three committees are
registered with and report the Federal Election Commission FEC con rmed
Secretary State,HillPAC will cease active and will terminate, ling the appropriate
termination report with the FEC, soon practicable. con rmed, Friends Hillary will
become dormant; any funds associated with this entity will only used during service
Secretary State for expenditures related maintaining and meeting any FBC requirements,
including ongoing reporting requirements. Hillary Clinton for President will continue exist
engage i.n activities necessary retire any outstanding debt. the extent required for these
purposes, will make expenditures maintain it, retire its debt, and meet any FEC
requirements, including ongoing reporting requirements. During tenure Secretary State, will not participate the operation d.eeision rnal